Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Registration of Qualified Mental Health Professionals [18 VAC 115 ‑ 80]
Action Initial regulations for registration of Qualified Mental Health Professionals
Stage Proposed
Comment Period Ended on 4/5/2019
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3/21/19  2:47 pm
Commenter: Jalisa Johnson, James Madison University

Occupational Therapists as QMHPs
 

My name is Jalisa Johnson. I am currently a Master of Occupational Therapy student at James Madison University, whom plans to practice and serve in the state of Virginia upon receiving licensure. One facet of occupational therapy that I cherish is our advocacy for mental health. Mental health is a fundamental aspect of occupational therapy, as it is embedded in the foundation of our profession. It globally impacts functional independence, solidifying the necessity for occupational therapy involvement, advocacy, and services. The role of occupational therapy and its importance in mental health is continually expressed within each course of my MOT program, as well as in my fieldwork placements.

All Occupational Therapists are required to take and pass a national exam and obtain licensure prior to practicing. This national exam encompasses all aspects of the human being, including the influences of mental health and management. With that being said, I believe Occupational Therapists are currently servicing as QMHPs and specific training to enhance our skills and practice is welcomed and valued. With that being said, the undue requirement of 1500 hours deserves review and amending prior to implementing this regulation.

We are asking that the Part II Requirements for Registration regulation 18VAC115-80-40 B.5. Requirements for registration as a QMHP-A and 18VAC115-80-50 B.4. Requirements for registration as a QMHP-C be changed from the current Emergency Regulations to the following replacement:

Licensure as an occupational therapist by the Board of Medicine (§ 54.1-2900 of the Code of Virginia) with a master’s or doctoral degree, and an internship or practicum of at least 500 hours with persons with mental illness or one year of experience in a mental health setting.

Thank you for your attention and consideration.

Sincerely,

Jalisa Johnson, MS, MOTS

CommentID: 70639